A New Reading of the Concept of “Necessary Expense” for the Purpose of calculating Real Profit

Abstract

This article discusses the concept of necessary and deductible expense for the purposes of calculating IRPJ and CSLL. The central theme is approached from the perspective of the constitutional norms that support the notion of “net income” and considering, in addition, the “principle of universality”, which governs income tax in Brazil. Finally, the work proposes a new reading of the theme, different from the one that has prevailed in the doctrinal writings and in the jurisprudence of the courts.